Sean L.

Proposed Amendment of Class E Airspace; Houston, TX FAA–2008– 1046/Airspace Docket No. 08–ASW–21 It is my pleasure to comment on the Proposed Amendment of Class E Airspace in Houston, Texas. As a rated Air Transport Pilot and Commuter Airline Captain, as well as a Certified Flight Instructor, I have experience in various flight conditions and airspace. In particular, I know the importance of class E airspace compared to class G airspace with regard to safety, in particular. Here, it seems it would be likely that class G airspace would become class E airspace. Class E airspace affords a pilot with separation that is not generally provided in class G airspace. In addition, there is a slight, albeit important difference in the distance a pilot has to be from the clouds and the visibility required when on a Visual Flight Rules flight plan. In class G airspace, during the day, at or below 1200 feet above the surface, a pilot must maintain at least 1 statute mile of visibility, and remain merely clear of clouds. At more than 1200 feet above the surface (and less than10,000 feet mean sea level), a pilot must maintain 1 statute mile of visibility, as well as remain 500 feet below clouds, 1000 feet above clouds, and at least 2,000 feet horizontal from clouds. Compared to class E airspace where a pilot (less than 10,000 feet mean sea level) is required to have 3 statute miles of visibility, and remain 500 feet below clouds, 1000 feet above clouds, and at least 2,000 feet horizontal clouds. My experience has taught me that the additional 2 statute miles of visibility required in class E airspace (in general) is crucial in seeing and avoiding other aircraft, particularly when airspace is busy. Moreover, adding additional class E airspace will surely increase the safety with regard to the additional RNAV approaches at an airport. In addition to the separation, my experience has taught me that the addition of an instrument approach procedure, and particularly an RNAV approach, will certainly increase air traffic. The stepped up requirements of Class E airspace would thus certainly embrace safety as air traffic increases. Therefore, I am in favor of the proposed addition of the class E airspace.